Virtual currency providers

Registering as a virtual currency provider

Virtual currency providers must be registered in the register of virtual currency providers maintained by the Financial Supervisory Authority (FIN-FSA). ‘Virtual currency provision’ refers to the issuance of a virtual currency, a virtual currency exchange service and its marketplace as well as a custodial wallet service.

According to the Act on Virtual Currency Providers:

a virtual currency issuer is a natural or legal person who issues a virtual currency

a virtual currency exchange service, practised by a natural or legal person as a business or professional activity, is:

the exchange of a virtual currency into legal tender or another virtual currency as a service

the exchange of a virtual currency into another commodity or the exchange of another commodity into a virtual currency as a service and

the operation of a marketplace where a provider’s customers may engage in the activities referred to in points (a) and (b) above

a wallet provider is a natural or legal person who holds virtual currency for the account of some other party or provides for the transfer or storage of virtual currency.

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Exemptions from the obligation to register

The obligation to register does not apply to:

a trader who provides virtual currency services within a limited network

a trader who provides virtual currency services occasionally in connection with other professional activities that require some other authorisation, registration or prior approval

virtual currencies issued by central banks and other authorities.

Submission of a registration application

Registration is applied for from the FIN-FSA by means of a registration application in writing. The content of the registration application provided for in the Act, together with statements attached to it, must be submitted either in Finnish or Swedish. In the case of possible additional statements, attachments in other languages may be approved, where necessary.

Registration applications and attachments should be sent to the FIN-FSA Registry either electronically or in paper form:

registry@fiva.fi or

Financial Supervisory Authority, PO Box 103, 00101 Helsinki.

The Registry will issue in the matter a journal number, which should also be used when submitting any additional statements.

For further information on, among other things, secured email as well as Registry contact information.

Key requirements on the content of the registration application

Sections 5-6 of the Act on Virtual Currency Providers provide for the content and statements to be included in the registration application. Regulations and guidelines issued pursuant to the powers given in the aforementioned Act are published in the FIN-FSA’s regulations and guidelines on virtual currency providers. The regulations and guidelines complement the registration requirements laid down in law.

The registration application must include:

a description of the services to be provided

the name, identifying and location information of the person submitting the application

an extract from the Register of Bankruptcies and Reorganisations, issued by the Legal Register Centre

if the person submitting the application is a natural person, an extract from the Guardianship Register

an extract from the Business Prohibition Register issued by the Legal Register Centre

if the person submitting the application is a legal person, a report of the fitness and propriety of the company’s management (fit & proper form, only available in Finnish and Swedish)

a statement on the holding and protection of client money

information on the marketing of services to be provided to customers (such as terms and conditions of agreement) as well as

information on customer identification and customer due diligence procedures, risk management systems and the prevention of money laundering and terrorism financing, including e.g.

a risk assessment of money laundering and terrorist financing (chapter 2 section 3 of the Act on Preventing Money Laundering and Terrorist Financing)

operating guidelines regarding customer due diligence procedures and obtaining customer information, ongoing monitoring and the obligation to obtain information as well as compliance with the reporting obligation (chapter 9 section 1 subsection 3 of the Act on Preventing Money Laundering and Terrorist Financing)

a description of how responsibilities have been assigned in the applicant’s organisation for duties relating to preventing money laundering and terrorist financing as well as

a description of the training and protection of employees (chapter 9 section 1 subsections 1 and 2 of the Act on Preventing Money Laundering and Terrorist Financing).

The FIN-FSA will obtain, by virtue of its office, extracts required for registration from the Register of Crimes and Sanctions as well as Compliance Reports. The significance of these statements and information as part of the assessment of reliability referred to in section 6 subsection 3 of the Act on Virtual Currency Providers is provided for in section 7 of the said Act.

Completion of the registration procedure in the FIN-FSA

Upon receipt of the registration application, the FIN-FSA will assess whether the service provider fulfils the requirements prescribed by law and will decide on the matter. If the application is insufficient, the FIN-FSA will ask for further clarification before deciding on the matter. The quality and completeness of the application will influence significantly the total processing time.

The provision of virtual currency services is prohibited on a conditional fine should the obligation to register not be complied with.